Kaywood Jr., Sam K.; Blissard, Judith M.; Bazar, Jason S.
June 2002
Tax Lawyer;Jun2002, Vol. 55 Issue 4, p1337
Academic Journal
Looks at developments on U.S. foreign activities and tax treaties. Provisions of the amended U.S.-Australia Income Tax Treaty; Treatment of foreign government owned entities; Taxation of non-resident aliens; Guidance issued by the Internal Revenue Service on the taxation of income from the international operation of ships or aircraft.


Related Articles

  • Rulings Hold Dividends on Stock Held Through Hybrid Entities Are Eligible for Zero Withholding Tax Benefit Under U.K. and Dutch Income Tax Treaties. Rowe, Kevin; Tanenbaum, Edward // Corporate Business Taxation Monthly;Oct2005, Vol. 7 Issue 1, p23 

    The article discusses rulings issued by the United States Internal Revenue Service and the Netherlands that hold that dividends on stock held through hybrid entities are eligible for zero withholding tax benefit under the British and Dutch income tax treaties. The article suggests that British...

  • Anti-Deferral and Anti-Tax Avoidance:Refl ections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income. Miller, Michael J.; Zhang, Libin // International Tax Journal;Jan2010, Vol. 36 Issue 1, p5 

    The article focuses on the application of tax treaties to hybrid entities earning non-FDAP income. It discusses the Article 1(6) of the 2006 U.S. Model Treaty on the basis of which U.S. has signed treaties with several countries including Belgium, Finland and Germany. It also discusses the...

  • International Taxation. Feinschreiber, Robert; Kent, Margaret // Corporate Business Taxation Monthly;Dec2001, Vol. 3 Issue 3, p53 

    Presents an update on taxation in the U.S. as of December 2001. Issues to which the Section 861 allocation and apportionment of the international taxation is relevant; Function of the Field Service Advice 200130007 issued by the U.S. Internal Revenue Service; Impact of treaties on the manner in...

  • United States Activities of Foreigners and Tax Treaties. Stone, N. Susan; Kuusisto, Mary B. // Tax Lawyer;Summer99, Vol. 52 Issue 4, p1231 

    Discusses tax-related activities in the United States (US). Details on income tax treaties with foreign countries; Shipping and transportation agreement; Temporary regulations in Treasury Decision issued by the US Internal Revenue Service; Tax-related cases and rulings.

  • IRS Announces Settlement Agreement Between Switzerland and the U.S. (IR-2009-75).  // Venulex Legal Summaries;2009 Q3, following p2 

    The article reports on an agreement among the U.S. Internal Revenue Service (IRS), the Justice Department and UBS AG concerning the IRS John Doe summons to obtain about 4,450 names of taxpayers with UBS accounts reached. The initial term of the summons sought as many as 52,000 accounts. Under...

  • Tax Briefing: Tax. Greene, Chris; Maddalena, Christina // Accountancy;Feb2001, Vol. 127 Issue 1290, p106 

    The article presents news related to business tax. The Inland Revenue, with Customs, has announced a package of measures to help businesses in financial difficulties. The reforms are in response to the recommendation of the government's working group on insolvency and corporate rescue...

  • TAXATION.  // International Law Update;Feb2010, Vol. 16, p29 

    The article reports on the decision of the Swiss Federal Administrative Tribunal that bank data does not have to be provided to the Internal Revenue Service (IRS) inspite of the 2009 assistance agreement between Switzerland and the U.S. The Tribunal stress that Swiss authorities can provide...

  • irs briefing.  // Practical Accountant;Aug2004, Vol. 37 Issue 8, p14 

    The article presents information related to various developments taking place with the U.S. Internal Revenue Service (IRS). The IRS is offering an incentive to encourage enrollment in and use of the Electronic Federal Tax Payment System. The IRS announced in IR-2004-78, that a new tax form,...

  • Excise Tax Refund: Are You Eligible? Harkavy, Jon; Aronstein, Haren R. // Risk Management (00355593);Apr83, Vol. 30 Issue 4, p7 

    This article provides information on how a firm who has paid U.S. federal excise taxes for insurance premiums placed with British insurers and reinsurers between January 1, 1975 and January 1, 1982 can apply for a refund. The tax refunds result from an Income Tax Treaty between the U.S. and...


Read the Article


Sorry, but this item is not currently available from your library.

Try another library?
Sign out of this library

Other Topics